17/01/25
Law 45/X/2024, dated 30 December, which approves the 2025 State Budget Law (2025 SB), has been published in the Official Gazette. You can view the document here.
This Law takes effect on 1 January 2025.
The tax provisions already outlined in the 2025 SB proposal have been generally approved - see PwC’s Tax Flash here. The newly introduced tax measures in the legislation are highlighted as follows:
I - Corporate Income Tax (CIT)
Limitation on the tax deductibility of net financing expenses
The limitation on the deductibility of debt financing expenses will no longer apply to public entities, as provided in paragraph 5 of Article 68 of the CIT Code.
II - Special Regime for Micro and Small-Sized Companies (Regime Jurídico Especial das Micro e Pequenas Empresas, REMPE)
Excluded from the regime, with effect from the financial year following the respective verification, are micro and small enterprises that exceed, by more than 30%, in any financial year, the turnover stipulated by law, in accordance with paragraph 5 of article 4 of the REMPE regime.
The 25% reduction in turnover for the application of the TEU rate for micro and small enterprises that do not have an ongoing tax infringement process, previously stipulated in paragraph 9 of article 41 of the REMPE regime, is revoked.
Deeds of amendment to the articles of association and closure are now exempt from payment of stamp tax, fees, as well as any emoluments and other legal charges, under the terms of paragraph 1 of article 44 of the REMPE Regime.
Taxpayers classified under the REMPE regime must have a visible device through which fiscally relevant documents are issued.
III - Withholding tax on real estate income
When the entities required to do so fail to withhold tax, the beneficiaries of real estate income obtained in the national territory can choose to file the respective statement and pay the final withholding tax due.
IV - Indirect Taxes
Carbon Tax: a carbon tax of CVE 550 (approx. € 5) is introduced, which applies to the issuance of commercial passenger air transport tickets at airports and aerodromes in Cabo Verde, as well as to the docking of passenger ships at Cabo Verde's port terminals.
There are some exceptions to its application, namely for air and maritime transport between the islands of Cabo Verde.
Excise Duties
Specific tax on sugary beverages drinks: Increase in the specific tax on imported sugary drinks.
Specific tax on sweet products: Increase in the specific tax on imports of sweet products.
V - Tax Incentives
Cumulating with the existing tax incentives, the following have been introduced:
Tourism: exemptions both from VAT and custom duties on imports of equipment necessary for implementing a program aimed at promoting sustainability in the tourism value chain, to be launched in 2025.
VI - Legal Framework for Non-Customs Tax Offences
A variable fine ranging from CVE 500,000 to CVE 2,500,000 (approx. € 4,500 to € 22,600) is introduced for the following offences:
Commercialization, transfer or provision of accounting and invoicing software via electronic means, which have not been previously certified by the Tax Authorities.
Failure to notify the Tax Authorities within the legally established deadlines of any changes or updates to previously certified software.
Use of software not certified by the Tax Authorities for the preparation of accounting records and the processing of electronic invoices and other tax-relevant electronic documents.
A variable fine ranging from CVE 30,000 to CVE 1,000,000 (approx. € 270 to € 9,000) is introduced for the failure to issue invoices and tax-fiscally relevant documents, or for issuing them outside the after the established legal deadlines.
© 2025 PwC. This communication is of an informative nature and intended for general purposes only. It does not address any particular person or entity nor does it relate to any specific situation or circumstance. PricewaterhouseCoopers Tax Services TLS, Lda. We will not accept any responsibility arising from reliance on information hereby transmitted, which is not intended to be a substitute for specific professional business advice.
Tax Partner – Corporate & International Tax, PwC Portugal
Tel: +351 213 599 618